Disclaimer: This material is for educational and informational purposes only. It is not legal, medical, or regulatory advice. Statutes, regulations, and board interpretations change. Always confirm current requirements with the Nevada State Board of Medical Examiners, Nevada State Board of Nursing, Nevada State Board of Pharmacy, and qualified legal counsel before acting.
Executive Summary
- Corporate Practice of Medicine (CPOM): Medical decision-making must remain under a Nevada-licensed MD/DO. MSOs are strictly limited to business operations (billing, marketing).
- Medical Director: Must be an actively licensed Nevada MD/DO with documented availability for supervision, emergencies, and Quality Assurance (QA).
- APRNs & PAs: APRNs may practice independently with Full Practice Authority (FPA). PAs require a current, written Supervisory Agreement with a physician, detailing scope and chart review.
- Scope of Practice Mapping: Maintain a written matrix detailing who may perform each procedure (injectables, lasers, IV therapy), verified against licensure and competency.
- Controlled Substances: Prescribers must have DEA registration and perform Nevada PMP checks before initiating or refilling Schedule II–IV medications (e.g., phentermine).
- Laser & Device Rules: Medical lasers, IPL, and RF devices may only be operated by licensed clinicians. Estheticians cannot use medical lasers in Nevada.
- Quality Assurance (QA): Requires documented chart reviews, QA meetings, competency sign-offs, and clear incident-tracking to show active physician oversight.
- Injections/Procedures: Procedures like injectables and IV therapy are medical acts and require physician oversight or orders; follow all informed consent and complication protocols.
- Telehealth Compliance: Telehealth is permitted but must adhere to Nevada’s standard of care, identity verification, and consent rules. Controlled substance prescribing requires specific DEA/PMP compliance.
- Required Paperwork: Regulators expect to see current licensure files, PA Supervisory Agreements, written protocols, QA logs, PMP documentation, and compliant marketing materials.
- Common Mistakes: Frequent errors include lack of physician control, using unlicensed staff (like estheticians) for medical procedures, and missing or outdated supervisory agreements/QA records.
- Implementation: Establish CPOM governance first, then launch documented QA workflows, and finally complete staff competency checks and update all protocols.
Nevada Regulatory Landscape
Nevada weight loss and telehealth clinics operate at the intersection of several legal regimes: physician and PA rules under NRS Chapter 630, nursing and APRN standards under NRS Chapter 632, controlled substance and prescription monitoring requirements in NRS Chapter 453, telehealth provisions in NRS Chapter 629, and pharmacy and compounding standards under NRS Chapter 639.
Because Nevada enforces the corporate practice of medicine through unprofessional conduct provisions and supervision duties rather than one stand alone CPOM statute, clinics must be structured so that physicians retain control of clinical decisions even when an MSO handles business operations.
Quick Compliance Checklist
A Nevada weight loss and telehealth clinic should be able to show:
- Physician controlled clinical entity with any MSO confined to non clinical functions such as billing, HR, and marketing.
- Nevada licensed MD or DO serving as medical director with responsibility for oversight and supervision.
- APRN licensure and scope that meets NRS 632.237, plus DEA registration and NV PMP enrollment if prescribing controlled substances
- PA supervision agreements or documentation showing authorized services under NRS 630.271.
- Documented chart reviews and scheduled QA meetings between supervising physicians and APRNs or PAs.
- DEA registration and NV PMP query practices for all Schedule II to IV prescriptions, including phentermine.
- Contracts and SOPs for GLP 1 sourcing that comply with Board of Pharmacy and FDA compounding policy.
- Telehealth workflows that align with NRS 629.515 regarding licensure, relationship formation, and applicable standards.
- Advertising must not be false or misleading under the Nevada Deceptive Trade Practices Act (NRS Chapter 598), which prohibits deceptive claims, inaccurate pricing statements, and misrepresentation of provider credentials.
The Legal Frame: CPOM and Medical Director Role
Corporate Practice of Medicine in Nevada
Who Can Be a Medical Director?
A medical director must be a Nevada licensed MD or DO in good standing under NRS Chapter 630. This physician is expected to oversee delegation to APRNs, PAs, and RNs; review charts and QA data; verify telehealth and prescribing compliance; and ensure all medical acts in the clinic meet Nevada’s professional conduct and supervision standards.
Delegation and Prescriptive Authority: Documents That Matter
- APRNs may diagnose, treat, and prescribe independently once they obtain Full Practice Authority under NRS 632.237; no collaborative agreement is required at that point.
- To prescribe controlled substances, APRNs must hold DEA registration and check the Nevada PMP as required under NRS 453.164.
- Medspa settings should still maintain written protocols for injectables, devices, and emergency procedures to document training and safety oversight.
- PAs may perform medical services only as authorized by a supervising physician, as stated in NRS 630.271, and must practice under board regulations that define supervision, prescribing authority, and chart review expectations.
- A written supervisory framework should clearly define scope, prescribing limits, and escalation pathways for weight loss and psychiatric related drugs.
Other Clinical Staff
- RNs practice under NRS Chapter 632 and may administer medications, injections, and IV therapy only under physician or APRN orders and consistent with their training and board standards.
- Medical assistants are not licensed independent practitioners; they may perform basic supportive tasks under supervision but may not diagnose, prescribe, or independently perform invasive procedures on living tissue. Unlicensed practice by assistants can lead to discipline under NRS 630.301 and 630.400.
Nevada Weight Loss Clinics: Core Requirements
Who can prescribe
- Weight loss medications may be prescribed by Nevada licensed physicians and APRNs who hold Full Practice Authority under NRS 632.237.
- PAs may prescribe only when authorized under a supervising physician, consistent with NRS 630.271 and prescribing limits set by the Nevada State Board of Medical Examiners.
- Prescribing controlled substances such as phentermine (Schedule IV) requires a DEA registration and mandatory Nevada PMP checks under NRS 453.164.
Delegation documents
- Clinics must maintain written Supervisory Agreements for PAs, as required by NRS 630.271 and associated board regulations (NAC 630.810–630.830).
- APRNs with Full Practice Authority do not need a collaborative agreement, but clinics should maintain written internal protocols documenting standardized workflows for APRN and RN roles in weight loss and wellness programs.
- RNs operate under physician or APRN orders per NRS Chapter 632, and protocols must define what tasks are delegated to nursing staff.
Clinic protocols
- Every medication or program offered — including phentermine, GLP 1 agents such as semaglutide and tirzepatide, and adjunctive IV therapy — should have written clinical protocols outlining patient inclusion criteria, contraindications, dosing guidance, monitoring requirements, adverse event response, and required follow-up.
- Protocols are required to support supervision and competency documentation under Nevada Medical Board standards and to demonstrate compliance with NRS 630.301 regarding safe medical practice.
Prescribing Weight Loss Medications
Phentermine and Other Controlled Substances
- Phentermine is a Schedule IV controlled substance, and prescribing requires compliance with Nevada’s Prescription Monitoring Program (PMP) and requirements under NRS 453.162 and NRS 453.164.
- Prescribers must check the PMP before issuing or refilling any Schedule II to IV medications as required by Nevada Board of Pharmacy regulations.
- Documentation should reflect a face-to-face or legally valid telehealth evaluation, individualized treatment plan, monitoring of weight and vitals, side-effect review, and periodic reevaluation of the therapy.
GLP-1 Medications (Semaglutide, Tirzepatide)
- GLP-1 medications are not controlled substances, but their prescribing must comply with FDA labeling, the Nevada State Board of Pharmacy rules, and applicable federal compounding requirements (503A and 503B).
- Clinics may obtain GLP-1s only from Licensed Nevada pharmacies, or FDA-registered 503B outsourcing facilities meeting federal and state safety standards.
- Compounding must meet all applicable requirements under the Nevada Board of Pharmacy and federal USP standards and must be clinically justified (for example, shortage or specific patient need).
- Physicians and APRNs may prescribe independently within their scope, while PAs may prescribe only when expressly authorized in their Supervising Physician Agreement under NRS 630.271.
IV Therapy, Supplements, and Adjuncts
- IV infusions, vitamin injections, and similar therapies are classified as medical treatments in Nevada and must follow written standing orders signed by a physician or an APRN.
- Protocols must outline approved substances and dosing, contraindications, monitoring requirements, and emergency response (for example, anaphylaxis).
- Personnel performing IV therapy must be appropriately licensed (RN, APRN, PA) and competence must be documented, consistent with Nevada Medical Board expectations for safe practice under NRS 630.301.
Advertising Rules
Prohibited Advertising Practices (Grounds for Discipline)
Nevada law explicitly prohibits physicians from advertising the practice of medicine in a false, deceptive, or misleading manner (NRS 630.304(2)), which is grounds for disciplinary action.
Specifically, clinics and telehealth providers must avoid the following types of claims:
- Guarantees: You cannot guarantee the results of any treatment or procedure (e.g., guaranteed weight loss).
- False Efficacy: You cannot make false claims about the value or effectiveness of a medication or treatment, including setting unverified rapid or fixed weight-loss timelines.
- Unrealistic Expectations: Advertisements cannot contain claims that are likely to mislead the public or create unrealistic expectations.
- Price Deception: You must not misrepresent the price, cost, or terms of credit for services.
- Credential Misrepresentation: You must not falsely describe or misrepresent the licensure, expertise, or training of any health care professional (e.g., implying non-physicians are doctors or have physician supervision when they do not).
Misrepresentation of Credentials
Clinics must be truthful about the titles, licenses, and supervision of their staff in all advertisements.
- Deceptive Professional Information (NRS 629.076): Advertising must not include any information that falsely describes or misrepresents the profession, skills, training, expertise, education, or licensure of a health care professional.
- False Medical Status (NRS 630.400): Presenting non-physicians as “doctor,” or implying medical licensure or physician supervision when those conditions are not true, constitutes a specific type of misrepresentation and deceptive advertising.
Telehealth in Nevada: Compliance Rules
Nevada maintains a flexible telehealth framework, but providers must follow licensure, patient-relationship, and documentation requirements and meet the same standard of care as in-person treatment.
Practitioner Patient Relationship
- NRS 629.515 requires that telehealth providers hold a valid Nevada license or certificate and allows a patient relationship to be established through telehealth if the technology enables an adequate evaluation.
- While Nevada law permits synchronous and certain asynchronous methods, a purely questionnaire-based encounter is generally not considered sufficient for medical evaluation under board expectations.
Standards of Care and Documentation
- Under NRS 629.515, telehealth encounters must meet the same standard of care as in-person visits. Providers must also comply with all Nevada and federal laws, including medical board rules and prescribing requirements.
- Documentation should reflect identity verification, informed consent for telehealth, clinical history and assessment, diagnosis, treatment rationale, and follow-up instructions.
Delegation in Telehealth
- Supervising physicians remain responsible for reviewing clinical documentation and prescriptions issued by APRNs and PAs they oversee. Delegation documents should explicitly cover telehealth services, prescribing parameters, and access to records so the physician can perform oversight consistent with NRS 630.271 (PAs) and NRS Chapter 632 (APRNs).
Telehealth Weight Loss Prescribing
- GLP 1 medications may be prescribed through telehealth when a valid practitioner-patient relationship is established and medical necessity is documented.
- Phentermine and other Schedule II–IV medications require compliance with federal DEA telemedicine rules and Nevada PMP laws. Best practice is to perform at least one live video or in-person evaluation before initiating controlled-substance therapy, especially for weight-loss treatment.
Enforcement Risks in Nevada
- Nevada State Board of Medical Examiners (NSBME)
Disciplines physicians and PAs for unprofessional conduct, including failure to supervise, aiding or abetting unlicensed practice, improper delegation, and inappropriate prescribing under NRS 630.301, NRS 630.306, and NRS 630.3062. - Nevada State Board of Nursing
Regulates APRNs and RNs under NRS Chapter 632. Disciplinary actions occur for exceeding scope, prescribing outside authority, failing to follow standards of care, or inadequate documentation. - Nevada State Board of Pharmacy
Enforces controlled-substance rules and Prescription Monitoring Program (PMP) participation under NRS Chapter 453; regulates compounding and drug distribution under NRS Chapter 639. - DEA
Enforces the federal Controlled Substances Act for weight-loss-related prescribing, with heightened scrutiny for telehealth initiation of Schedule III and IV medications like phentermine. - Civil Litigation
Clinics may face malpractice claims or Nevada consumer protection claims (under NRS 598, Deceptive Trade Practices Act) related to improper prescribing, inadequate supervision, or misleading advertising.
FAQs
Can a nonphysician own a Nevada weight-loss clinic?
Yes. A nonphysician may own an MSO, but clinical services must be controlled by Nevada-licensed physicians. Nonphysicians may not practice medicine or influence medical judgment due to unlicensed practice prohibitions in NRS 630.400 and unprofessional-conduct rules in NRS 630.301.
Can an APRN run a weight-loss program?
Yes. An APRN with Full Practice Authority under NRS 632.237 may independently diagnose, treat, and prescribe within scope. They must still comply with telehealth standards, PMP requirements for controlled substances, and all documentation obligations.
Do PAs always need a supervisory arrangement?
Yes. PAs must practice under a supervising physician as required by NRS 630.271. Supervisory conditions, prescribing authority, and chart review expectations must follow NSBME regulations.
Is telehealth prescribing of phentermine allowed?
Yes, but only by a DEA-registered prescriber who complies with federal telemedicine rules and Nevada PMP requirements under NRS 453.162 and 453.164. A clinically adequate evaluation must be documented; video or in-person assessment is strongly preferred.
Can estheticians independently offer weight-loss treatments?
No. Estheticians are regulated under the Nevada State Board of Cosmetology and cannot perform medical acts, including prescribing, diagnosing, injections, IV therapy, or any procedure affecting living tissue. Doing so constitutes unlicensed practice under NRS 630.400.
How Medical Director Co. Supports Nevada Weight Loss and Telehealth Clinics
Medical Director Co. delivers compliant, physician-led oversight for Nevada medical and wellness practices.
- Nevada licensed physicians: We match clinics with Nevada licensed MDs and DOs who understand CPOM enforcement, weight loss pharmacotherapy, and telehealth workflows.
- Delegation and protocol templates: We provide Nevada specific templates for PA supervision language, APRN protocols, and clinic SOPs for phentermine, GLP 1s, and IV therapies.
- QA and audit readiness: Our systems include chart review schedules, meeting templates, and documentation trackers designed to show compliance with NRS 630 and related board standards.
- Telehealth playbooks: We help design telehealth processes that align with NRS 629.515, DEA expectations, and NV PMP usage, including red flag escalation and follow up rules.
- Compounding and pharmacy coordination: We guide clinics on working with compliant pharmacies and outsourcing facilities for GLP 1 sourcing and labeling.
- MSO structure review: We examine management contracts to help keep business control and clinical control properly separated under Nevada’s unprofessional conduct rules.
Areas We Serve in Nevada
Medical Director Co. matches Nevada medspas with licensed physicians who provide compliant oversight, supervision, and protocol support across the state.
Areas We Serve in Nevada:
Who We Serve
Medical Director Co. supports Nevada healthcare professionals and wellness operators by providing physician oversight, supervision frameworks, and compliance systems that align with Nevada State Board of Medical Examiners, Nevada Board of Nursing, and Nevada Board of Pharmacy rules. We help ensure every provider operates safely and legally within Nevada-defined scopes of practice.
- Nurse Practitioners (APRNs): Independent practice support for APRNs with Full Practice Authority; prescribing compliance, PMP requirements, and medspa protocol development.
- Registered Nurses (RNs): Oversight for injectables, IV therapy, and device-based services performed under physician or APRN orders, with training and competency documentation.
- Physician Assistants (PAs):
Supervisory structure development, procedure and prescribing protocols, and chart review systems in compliance with NRS 630.271 and Board regulations. - Estheticians: Support for non-medical cosmetic service integration and clear differentiation between cosmetic and medical procedures, ensuring no unlicensed practice.
Nevada Resources and References
- DEA Diversion Control Division: https://www.dea.gov/press-releases/2025/01/16/dea-announces-three-new-telemedicine-rules-continue-open-access
- Nevada Revised Statutes – Justia: https://law.justia.com/codes/nevada/2024/
- Nevada Medical Board: https://medboard.nv.gov/
- Nevada Public Law Statutes: https://nevada.public.law/statutes
- Nevada Admin Code – Legal Information Institute: https://www.law.cornell.edu/regulations/nevada/
